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MLP Qualifying Income

Qualifying Income Resources

Vinson & Elkins has extensive experience with the tax treatment of master limited partnerships (MLPs) and the definition of “qualifying income” for MLPs. We have also pioneered the application of these rules to numerous asset classes.

Treatment of an MLP as a partnership for federal income tax purposes requires that 90 percent or more of the MLP’sgross income for every taxable year consists of “qualifying income.” In the context of a public offering, MLP investors require a high level of certainty with respect to the qualifying income nature of the MLP’s income-generating activities. If there is uncertainty as to the nature of an activity, it is possible to seek a private letter ruling (PLR) from the Internal Revenue Service with respect to the treatment of such activity.

The Treasury Department has recently proposed regulations that provide guidance on whether certain activities with respect to minerals or natural resources generate qualifying income. For a discussion of the proposed regulations, click here. Information regarding the proposed regulations, including relevant authorities and public comments in response to the proposed regulations, are available below. These materials reflect the opinions of the applicable authority or commentator as of the date of their submission and do not necessarily reflect the views of Vinson & Elkins LLP.

Qualifying Income Authorities

Comments to Proposed Regulations

Comments to the proposed regulations are organized in various ways below. Select the method of organization and expand subheadings as necessary. To view the full text of the comments, please click on the name of the comment.

Name Date Topic
Master Limited Partnership Association April 16, 2016 Other
PricewaterhouseCoopers LLP January 14, 2016 Processing and Refining; Transition Rule
American Bar Association Section of Taxation January 4, 2016 Natural Resource; Processing and Refining; Transportation; Marketing; Intrinsic Activities; Transition Rule; Passive Economic Interest
Vinson & Elkins LLP November 24, 2015 Processing and Refining; Natural Resource
U.S. Senators Vitter and Cassidy October 29, 2015 Processing and Refining
Congress of the United States – Members of the House of Representatives September 22, 2015 Processing and Refining
Riverstone: Riverstone Holdings LLC August 7, 2015 Processing and Refining
Gas Processors Association August 4, 2015 Processing and Refining; Transition Rule
Baker Botts LLP August 4, 2015 Processing and Refining; Intrinsic Activities; Transportation; Marketing; Transition Rule
Financial Executives International/U.S. Chamber of Commerce August 4, 2015 Transition Rule
National Association of Publicly Traded Partnerships August 4, 2015 Marketing; Intrinsic Activities; Operation and Management; Passive Economic Interest; Processing and Refining; Transportation; Transition Rule; Natural Resource
Tax Executives Institute, Inc. August 3, 2015 Transition Rule
Foxhill Capital partners, LLC et al. August 3, 2015 Processing and Refining
National Propane Gas Association July 31, 2015 Transportation; Marketing
Baron Capital Group July 29, 2015 Processing and Refining; Transition Rule
Andrews Kurth LLP July 29, 2015 Processing and Refining
Congress of the United States – State of Louisiana Members of Congress July 20, 2015 Processing and Refining
Vinson & Elkins LLP June 19, 2015 Processing and Refining; Natural Resource
Name Date Topic
Goldberg, Martin August 7, 2015 Transition Rule
Sheridan, Kevin August 7, 2015 Processing and Refining; Transition Rule
Anonymous August 7, 2015 Transition Rule
B., Jerry August 7, 2015 Processing and Refining; Transition Rule
Anonymous August 7, 2015 Transition Rule
K.J. August 7, 2015 Processing and Refining; Transition Rule
Goldsmith, Bruce August 7, 2015 Processing and Refining; Transition Rule
Anonymous August 7, 2015 Transition Rule
Allen, Theo August 7, 2015 Transition Rule; Transportation
LeSatz, Stephen Jr. August 7, 2015 Processing and Refining; Transition Rule
Ross, Melinda August 7, 2015 Processing and Refining
VanderVliet, Marvin August 7, 2015 Processing and Refining; Transition Rule
Horton, Cort August 7, 2015 Processing and Refining; Transition Rule
Anonymous August 7, 2015 Processing and Refining; Transition Rule
Whitaker, William August 7, 2015 Processing and Refining; Transition Rule
Anonymous August 7, 2015 Processing and Refining
Jennings, Stephen August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Transition Rule
Shannon, William August 7, 2015 Transition Rule
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Wang, Jingci August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Lipkowitz, Sandra August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Anonymous August 7, 2015 Processing and Refining
Sweeten, Michael August 7, 2015 Processing and Refining
Lin, Alice August 4, 2015 Processing and Refining
Yates, Bobby August 4, 2015 Processing and Refining
Anonymous August 4, 2015 Processing and Refining
Michelotti, Donald August 4, 2015 Other
Anonymous August 4, 2015 Processing and Refining
Anonymous August 4, 2015 Processing and Refining
Owens, J. August 4, 2015 Other
Casey, John August 4, 2015 Processing and Refining
Ahrens, Bradley James August 4, 2015 Processing and Refining
Hadick, David August 4, 2015 Processing and Refining
Vermillion, Victor August 4, 2015 Processing and Refining
Anonymous August 4, 2015 Processing and Refining
Bailey, Timothy August 4, 2015 Processing and Refining
Tucci, Robert August 4, 2015 Processing and Refining
Adams, James August 4, 2015 Processing and Refining
Neumann, Adolf August 4, 2015 Processing and Refining
Adams, R. August 4, 2015 Processing and Refining
Markovic, David August 4, 2015 Other
Shah, Mahesh July 31, 2015 Processing and Refining
Anonymous July 31, 2015 Processing and Refining
Wallace, Stephen July 31, 2015 Processing and Refining
Anonymous July 31, 2015 Processing and Refining
Anonymous July 31, 2015 Processing and Refining
Hearron, Justin July 31, 2015 Processing and Refining
Yates, P. July 31, 2015 Processing and Refining
Dunning, Jerry July 31, 2015 Processing and Refining
Anonymous July 31, 2015 Processing and Refining
Anonymous July 31, 2015 Processing and Refining
Anonymous July 27, 2015 Processing and Refining
Azevedo, Maurice July 27, 2015 Processing and Refining
Armada Advisors July 21, 2015 Processing and Refining
Ahrens, W. July 21, 2015 Processing and Refining
Kendrigan, James July 15, 2015 Processing and Refining
Allen, Nancy July 15, 2015 Processing and Refining
Anonymous July 15, 2015 Processing and Refining
Moore, Bradley July 13, 2015 Processing and Refining
Anonymous July 8, 2015 Other
Anonymous July 8, 2015 Processing and Refining
Anonymous July 8, 2015 Processing and Refining
Faber, John July 8, 2015 Processing and Refining
Watkins, Louis July 8, 2015 Processing and Refining
Anonymous July 6, 2015 Processing and Refining
Palma, James July 6, 2015 Processing and Refining
Bullock, Charles July 6, 2015 Processing and Refining
Anonymous July 6, 2015 Processing and Refining
Butler, S. July 6, 2015 Processing and Refining
Bredt, Barry July 6, 2015 Processing and Refining
Dieterle, Richard June 30, 2015 Other
Killingsworth, Eddy June 30, 2015 Processing and Refining
Anonymous June 25, 2015 Processing and Refining
Bender, David June 25, 2015 Processing and Refining
Bloomer, Richard June 23, 2015 Processing and Refining
Taylor, Jeffrey June 23, 2015 Processing and Refining
Vankadaru, Pavan June 23, 2015 Other
Gross, Steven June 22, 2015 Processing and Refining
Baxley, Clay May 16, 2015 Processing and Refining
Anonymous May 7, 2015 Processing and Refining
Name Date Topic
Enviva Partners, LP April 13, 2016 Marketing
Cypress Energy Partners, L.P. August 7, 2015 Transportation; Intrinsic Activities
ADA Carbon Solutions August 7, 2015 Processing and Refining
ZoeGas LLC August 4, 2015 Processing and Refining
Plains All American Pipeline, LP August 4, 2015 Marketing; Intrinsic Activities; Operation and Management; Passive Economic Interest; Processing and Refining; Transportation
Siluria Technologies, Inc. August 4, 2015 Processing and Refining; Transition Rule
Velocys, Inc. August 4, 2015 Processing and Refining; Transition Rule
BGPLLC August 4, 2015 Processing and Refining; Transition Rule
Sempra Energy August 4, 2015 Processing and Refining; Marketing; Transportation
Greyrock Energy, Inc. August 4, 2015 Processing and Refining
G2X Energy, Inc. August 4, 2015 Processing and Refining
OCI Partners LP August 4, 2015 Processing and Refining; Natural Resource
Western Refining, Inc. August 4, 2015 Processing and Refining; Transportation
Quality Magentite, LLC August 4, 2015 Processing and Refining; Marketing
Enviva Partners, LP August 4, 2015 Processing and Refining
Vulcan Materials Company August 4, 2015 Processing and Refining
Calumet Specialty Products Partners, L.P. August 4, 2015 Processing and Refining; Marketing
MarkWest Energy Partners, L.P. August 4, 2015 Processing and Refining; Operation and Management; Transportation
Martin Midstream Partners L.P. August 3, 2015 Transportation; Intrinsic Activities; Marketing
Exterran Partners, L.P. August 3, 2015 Transportation
Dominion Midstream Partners, L.P. August 3, 2015 Transportation
Select Energy Services, LLC July 31, 2015 Intrinsic Activities
Buckeye Partners, L.P. July 31, 2015 Marketing; Transportation; Operation and Management
Enterprise Products Partners L.P. July 31, 2015 Processing and Refining
Black Stone Minerals LP July 30, 2015 Passive Economic Interest
Holly Energy Partners, L.P. July 29, 2015 Transportation, Intrinsic Activities
Westlake Chemical Partners LP July 28, 2015 Processing and Refining, Transition Rule
AmeriGas Partners, L.P. June 26, 2015 Marketing
Sprague Resources LP July 24, 2015 Processing and Refining
Boardwalk Pipeline Partners, LP July 23, 2015 Processing and Refining
Targa Resource Partners LP June 22, 2015 Processing and Refining;
Operation and Management
SunCoke Energy Partners, L.P. June 16, 2015 Processing and Refining
Suburban Propane Partners L.P. June 4, 2015 Marketing

Our corporate and tax lawyers have advised on 80 percent of all natural resource or real estate MLP initial public offerings completed. In many of those instances, we have assisted our clients in obtaining PLRs for their assets. Recent interest in nontraditional MLP asset classes has led to an increasing number of PLRs addressing MLP qualifying income. Our historical experience in the market, combined with our ongoing involvement in the development of these nontraditional asset classes, provides us with unique positioning to assist our potential MLP clients in obtaining a PLR, regardless of industry or operations.

Below is a list of the activities addressed by IRS guidance (including PLRs) relative to MLP qualifying income. To view the full text of the IRS document, please click on the PLR number. These PLRs represent the interpretation of the IRS prior to the release of proposed Treasury regulations concerning qualifying income on May 5, 2015 and may not reflect the current position of the IRS with respect to certain activities.

IRS Guidance Date Activity
PLR 2016-37-007 June 13, 2016 139. Fluid management, transportation, disposal, washout, and storage services, including hydrocarbon remediation
PLR 2016-33-020 April 18, 2016 135. Fluid management and disposal services, including sale of recovered hydrocarbons and minerals
PLR 2016-14-004 April 1, 2016 134. Oil and natural gas transportation, gathering and storage activities, interconnect activities, fluids transportation, collection, recycling and disposal, hedging
PLR 2016-11-017 March 11, 2016 133. Water sourcing, distribution, transportation, recycling and disposal, pressure pumping and production support services
PLR 2016-08-011 February 19, 2016 132. Fluids hauling, storage, and disposal services, selling filtered hydrocarbons
PLR 2016-02-004 January 8, 2016 131. Water supply and oilfield fluids and solids handling, recycling and disposal, washout activities
PLR 2015-48-013 November 27, 2015 130. Fluid handling, treatment, processing and disposal services, hot oiler and superheater services, slurry injection, condensate vapor control and battery vapor services, washout activities
PLR 2015-45-002 November 6, 2015 129. Fluid delivery, handling, treatment, processing, and disposal services
PLR 2015-37-014 May 29, 2015 126. Water supply and oil field fluids handling, recycling and disposal
PLR 2015-49-004 May 26, 2015 125. Water supply and oilfield fluids handling, treatment and processing services
PLR 2014-16-003 December 27, 2013 119. Water supply and oilfield fluids handling and transportation services
PLR 2014-14-002 December 16, 2013 118. Water supply and oilfield fluids handling and transportation services
PLR 2014-12-007 November 25, 2013 117. Redacted oilfield services with customer contracts
PLR 2014-10-017 October 28, 2013 112. Oilfield fluids handling and disposal services
PLR 2014-18-021 October 25, 2013 111. Oilfield infrastructure construction and support services
PLR 2014-14-004 September 11, 2013 105. Wholesale marketing and transportation of frac sand
PLR 2014-20-012 August 30, 2013 104. Well-site oilfield services and supervision
PLR 2013-47-001 July 23, 2013 102. Fluids handling, storage, and storage connection and maintenance services
PLR 2013-47-015 July 22, 2013 101. Access and throughput activities, logistics services, and supply of refined products and chemicals to E&P companies
PLR 2013-41-011 June 26, 2013 99. Fluids handling (including tank storage services, and the recycling of flowback and skim oil)
PLR 2013-38-001 May 30, 2013 97. Wholesale distribution of an undisclosed products and sale and delivery of refined products and chemicals to E&P companies
PLR 2013-38-035 May 9, 2013 95. Oilfield services, fluids management, waste treatment and disposal, fuel distribution and pipeline inspections
PLR 2013-36-016 May 7, 2013 94. Oilfield fluids management and technologies
PLR 2013-36-006 April 22, 2013 93. Brine treatment and disposal
PLR 2013-30-023 April 22, 2013 92. Fluids handling and hot oiler services
PLR 2013-30-027 April 18, 2013 91. Mining and processing kaolin into ceramic proppants
PLR 2013-30-026 April 18, 2013 90. Mining, processing and marketing of sand and ceramic proppants and well stimulation products
PLR 2013-30-024 April 10, 2013 88. Fluids handling (frac fluids, produced water and sale of recovered products)
PLR 2013-22-024 January 31, 2013 85. Hydraulic Fracturing Services (using mobile hydraulic fracturing units and associated heavy equipment)
PLR 2013-16-005 December 27, 2012 82. Updating EIN for PLR 2012-33-009 (frac sand mining and sale)
PLR 2012-34-005 May 11, 2012 70. Oilfield water pipeline
PLR 2012-27-002 March 1, 2012 65. Oilfield waste and environmental services
PLR 2012-27-001 March 1, 2012 64. Oilfield and mining fuel and lube transportation
PLR 2012-33-009 February 10, 2012 63. Extracting and marketing a natural resource to industrial users
PLR 2012-22-029 February 9, 2012 62. Produced water services
PLR 2012-26-018 December 7, 2011 61. Extractive logistics (fuels, lubes and chemical sales)
PLR 2011-37-005 June 1, 2011 56. Fluid handling (fracturing and produced water)
PLR 2010-43-024 July 12, 2010 49. Fluid handling (fracturing and acid mining)
PLR 2009-09-006 November 21, 2008 40. Seismic services
PLR 2008-27-022 March 26, 2008 36. Well servicing, workovers, and completion services
PLR 2008-27-014 February 8, 2008 34. Fluid handling (fracturing)
IRS Guidance Date Activity
PLR 2016-08-011 February 19, 2016 132. Fluids hauling, storage, and disposal services, selling filtered hydrocarbons
PLR 2013-30-027 April 18, 2013 91. Mining and processing kaolin into ceramic proppants
PLR 2013-30-026 April 18, 2013 90. Mining, processing and marketing of sand and ceramic proppants and well stimulation products
PLR 2013-16-005 December 27, 2012 82. Updating EIN for PLR 2012-33-009 (frac sand mining and sale)
PLR 2012-27-001 March 1, 2012 64. Oilfield and mining fuel and lube transportation
PLR 2012-33-009 February 10, 2012 63. Extracting and marketing a natural resource to industrial users
PLR 97-12-024 December 20, 1996 15. Sales to governmental authorities
IRS Guidance Date Activity
PLR 2017-51-006 October 22, 2017 148. Supply and transportation of water and brine for use in fracturing and drilling; treatment and disposal of waste streams; removal of oilfield waste material from equipment; sale of hydrocarbons recovered from oilfield waste
PLR 2017-36-020 June 7, 2017 146. Crude oil transportation via pipeline; income from construction and reimbursement payments
PLR 2017-32-006 May 16, 2017 145. Delivery, handling, treatment, recycling and disposal of produced water; transportation and storage of oilfield drilling and completion fluids
PLR 2017-28-021 April 17, 2017 144. Extraction of NGLs to meet interstate pipeline gas quality specifications
PLR 2017-24-024 March 9, 2017 143. Construction and expansion of transportation systems and processing facilities; operation of third-party assets
PLR 2017-21-007 February 23, 2017 141. Early termination of certain processing, refining, and transportation agreements; receipt of reimbursement payments and accelerated tolling and tariff fees
PLR 2017-23-004 January 25, 2017 140. Fluid management, inter-well transfer, disposal, and hydrocarbon remediation services
PLR 2016-36-025 May 26, 2016 137. LNG regasification pursuant to agreement with fixed monthly capacity fee
PLR 2016-14-004 April 1, 2016 134. Oil and natural gas transportation, gathering and storage activities, interconnect activities, fluids transportation, collection, recycling and disposal, hedging
PLR 2016-11-017 March 11, 2016 133. Water sourcing, distribution, transportation, recycling and disposal, pressure pumping and production support services
PLR 2016-08-011 February 19, 2016 132. Fluids hauling, storage, and disposal services, selling filtered hydrocarbons
PLR 2016-02-004 January 8, 2016 131. Water supply and oilfield fluids and solids handling, recycling and disposal, washout activities
PLR 2015-48-013 November 27, 2015 130. Fluid handling, treatment, processing and disposal services, hot oiler and superheater services, slurry injection, condensate vapor control and battery vapor services, washout activities
PLR 2015-45-002 November 6, 2015 129. Fluid delivery, handling, treatment, processing, and disposal services
PLR 2015-38-012 May 19, 2015 123. Transportation, storage and marketing of a redacted product
PLR 2014-51-002 September 8, 2014 121. Crude oil and natural gas gathering, natural gas processing, crude oil and NGL terminaling services, and transportation services (including crude oil transportation by rail)
PLR 2014-17-005 October 21, 2013 110. Crude and refined products transportation pursuant to time charters
PLR 2014-03-004

 

September 16, 2013 108. Terminal additization and blending activities
PLR 2014-03-008 September 13, 2013 107. Grease blending and wholesale distribution of grease
PLR 2013-47-015 July 22, 2013 101. Access and throughput activities, logistics services, and supply of refined products and chemicals to E&P companies
PLR 2013-37-014 May 30, 2013 96. Refining, processing, storage and handling of NGLs and related products
PLR 2013-28-005 April 2, 2013 87. Relocating pipelines and related facilities, the construction, installation, maintenance and operation of interconnects to pipelines, that sale of condensate from pipelines
PLR 2013-13-014 December 11, 2012 79. Operating natural gas compressor fleet
PLR 2013-14-029 November 28, 2012 78. Fees and expenses from constructing expansion facilities
PLR 2012-33-010 April 20, 2012 68. Gas gathering, amine plant and management fees for gas processing and NGL storage
PLR 2012-32-008 April 19, 2012 67. Terminal additization and blending activities
PLR 2012-24-023 March 8, 2012 66. LNG processing and marketing
PLR 2012-06-004 October 31, 2011 58. Terminal additization and blending activities
PLR 2011-32-020 May 6, 2011 55. Butane blending services
PLR 2011-32-012 April 29, 2011 54. Management fees for natural gas processing and NGL fractionation and storage
PLR 2010-25-037 March 12, 2010 48. Marine services to terminal customers
PLR 2008-45-035 July 31, 2008 38. Customer reimbursement of pipeline construction
PLR 2007-40-010 June 27, 2007 32. Pipeline and terminal management
PLR 2007-12-002 December 7, 2006 27. Terminal additization and pipeline and terminal management
PLR 2006-38-018 June 13, 2006 26. Terminal additization and pipeline management
PLR 2005-51-002 September 20, 2005 24. LNG and crude transportation pursuant to time charters
PLR 2004-22-023 February 10, 2004 23. Additization and pipeline management
PLR 2003-45-019 August 6, 2003 21. Operating and leasing property
PLR 99-04-025 November 2, 1998 19. Natural gas storage
PLR 96-39-011 May 20, 1996 13. Natural gas processing
PLR 94-52-013 September 26, 1994 10. Natural gas storage
PLR 94-16-033 January 24, 1994 7. Butane storage
PLR 93-40-031 July 6, 1993 6. Terminaling operations
IRS Guidance Date Activity
PLR 2015-37-007 May 26, 2015 124. Liquefaction of natural gas and regasification of LNG
PLR 2014-48-019 May 22, 2014 120. Processing iron ore into direct reduced iron
PLR 2014-08-025 November 13, 2013 116. Processing feedstock into redacted products
PLR 2014-08-008 October 29, 2013 114. Operating an air separation unit within a crude oil refinery
PLR 2013-49-004 August 29, 2013 103. Conversion of butane into butadiene and byproducts and the marketing, transportation and storage of the resulting products
PLR 2013-46-007 July 18, 2013 100. Processing natural gas into methanol and synthesis gas
PLR 2013-40-011 June 26, 2013 98. Processing natural resources and selling, storing and transporting resulting products
PLR 2013-37-014 May 30, 2013 96. Refining, processing, storage and handling of NGLs and related products
PLR 2013-24-002 February 21, 2013 86. Processing natural gas into gasoline, LPG, methanol, and synthesis gas (gas-to-liquids)
PLR 2013-15-005 January 3, 2013 83. Processing natural gas into gasoline and LPG (gas to liquids)
PLR 2013-14-038 December 12, 2012 80. Processing natural gas into DME (gas-to-liquids)
PLR 2013-01-010 September 28, 2012 76. Refining, processing, blending, packaging, and marketing, including bulk end-user sales, of crude and hydrocarbon-based natural resources
PLR 2012-41-004 July 2, 2012 73. NGL processing and olefin marketing, transportation, and storage
PLR 2012-36-005 June 5, 2012 71. Natural resource conversion by dehydrogenation and catalytic cracking
PLR 2011-41-013 April 7, 2011 53. Refinery services
PLR 2011-29-028

 

April 7, 2011 52. Refined product processing, marketing, packaging and distribution
PLR 2007-18-005 January 19, 2007 28. Processing and marketing of highly refined lubricating oils
IRS Guidance Date Activity
PLR 2016-08-011 February 19, 2016 132. Fluids hauling, storage, and disposal services, selling filtered hydrocarbons
PLR 2015-41-008 June 29, 2015 127. Wholesale fuel distribution
PLR 2014-11-004 November 08, 2013 115. Sale of EPA credits (RINs) and fuel delivery services
PLR 2013-38-001 May 30, 2013 97. Wholesale distribution of an undisclosed products and sale and delivery of refined products and chemicals to E&P companies
PLR 2013-38-035 May 9, 2013 95.  Oilfield services, fluids management, waste treatment and disposal, fuel distribution and pipeline inspections
PLR 2013-13-015 December 18, 2012 81. Operating and management fees from transportation and storage
PLR 2013-14-029 November 28, 2012 78. Fees and expenses from constructing expansion facilities
PLR 2013-01-010 September 28, 2012 76. Refining, processing, blending, packaging, and marketing, including bulk end-user sales, of crude and hydrocarbon-based natural resources
PLR 2012-50-014 August 15, 2012 74. Wholesale distribution of refined products and natural gas
PLR 2012-41-004 July 2, 2012 73. NGL processing and olefin marketing, transportation, and storage
PLR 2012-32-020 April 27, 2012 69. Sale of EPA credits (RINs) from blending renewables
PLR 2012-32-008 April 19, 2012 67. Terminal additization and blending
PLR 2012-26-018 December 7, 2011 61. Extractive logistics (fuels, lubes and chemical sales)
PLR 2012-06-004 October 31, 2011 58. Terminal additization and blending activities
PLR 2011-32-020 May 6, 2011 55. Butane blending services
PLR 2011-29-028 April 7, 2011 52. Refined product processing, marketing, packaging and distribution
PLR 2010-27-003 March 5, 2010 47. Marine transportation of products including ethanol and biodiesel
PLR 2009-39-016 June 25, 2009 45. Marine transportation of products including ethanol and biodiesel
PLR 2009-27-002 March 23, 2009 44. Sales of asphalt (with additives)
PLR 2009-21-010 February 10, 2009 42. Refined product storage and handling and ethanol blending
PLR 2008-48-018 August 26, 2008 39. Refined product marketing, packaging and distribution
CCA 2007-49-012 August 15, 2007 33. Retail propane sales
PLR 2007-40-010 June 27, 2007 32. Pipeline and terminal management
PLR 2007-18-005 January 19, 2007 28. Processing and marketing of highly refined lubricating oils
PLR 2007-12-002 December 7, 2006 27. Terminal additization and pipeline and terminal management
PLR 2006-38-018 June 13, 2006 26. Terminal additization and pipeline management
PLR 96-19-011 January 30, 1996 12. Derivative transactions, financing and inventory arrangements, separate services and end-user sales
PLR 94-16-033 January 24, 1994 7. Butane storage
PLR 93-40-031 July 6, 1993 6. Terminaling operations
IRS Guidance Date Activity
PLR 2015-49-013 August 19, 2015 128. Leasing of cell towers and billboards
PLR 2012-50-003 September 6, 2012 75. Leasing of an offshore production platform as rents from real property
PLR 2010-05-018 October 6, 2009 46. Leasing of refined product terminal
PLR 2009-37-006 March 3, 2009 43. Leasing natural gas local distribution company (REIT)
PLR 2007-25-015 March 13, 2007 30. Leasing electrical transmission and distribution assets (REIT)
PLR 2003-45-019 August 6, 2003 21. Operating and leasing property
PLR 97-43-006 July 18, 1997 16. Rents from parking and dry storage
PLR 94-20-013 February 15, 1994 8. Temporary hotel ownership as real estate investor
IRS Guidance Date Activity
PLR 2014-48-019 May 22, 2014 120. Processing iron ore into direct reduced iron
PLR 2013-51-009 September 12, 2013 106. Processing iron ore into iron pellets through beneficiation and pelletizing processes
PLR 2012-01-002 July 7, 2011 57. Natural resource processing, transporting, storing and marketing
PLR 2011-14-001 September 27, 2010 50. Sales of unstated natural resource
PLR 95-38-016 June 21, 1995 11. Smelting of alumina
IRS Guidance Date Activity
PLR 2017-36-020 June 7, 2017 146. Crude oil transportation via pipeline; income from construction and reimbursement payments
PLR 2017-24-024 March 9, 2017 143. Construction and expansion of transportation systems and processing facilities; operation of third-party assets
PLR 2017-21-007 February 23, 2017 141. Early termination of certain processing, refining, and transportation agreements; receipt of reimbursement payments and accelerated tolling and tariff fees
PLR 2012-33-010 April 20, 2012 68. Gas gathering, amine plant and management fees for gas processing and NGL storage
PLR 2014-18-021 October 25, 2013 112. Operating and management fees and reimbursements from coal mining
PLR 2013-28-005 April 2, 2013 87. Relocating pipelines and related facilities, the construction, installation, maintenance and operation of interconnects to pipelines, that sale of condensate from pipelines
PLR 2013-13-015 December 18, 2012 81. Operating and management fees from transportation and storage
PLR 2013-13-014 December 11, 2012 79. Operating natural gas compressor fleet
PLR 2011-32-012 April 29, 2011 54. Management fees for natural gas processing and NGL fractionation and storage
PLR 2007-40-010 June 27, 2007 32. Pipeline and terminal management
PLR 2007-12-002 December 7, 2006 27. Terminal additization and pipeline and terminal management
PLR 2006-38-018 June 13, 2006 26. Terminal additization and pipeline management
PLR 2004-22-023 February 10, 2004 23. Additization and pipeline management
IRS Guidance Date Activity
PLR 2016-36-039 June 8, 2016 138. Interest rate hedging financial transactions
PLR 2016-14-004 April 1, 2016 134. Oil and natural gas transportation, gathering and storage activities, interconnect activities, fluids transportation, collection, recycling and disposal, hedging
PLR 2015-23-018 January 29, 2015 122. Interest Rate Hedging (Locks, Swaps, and Interest Rate Caps)
PLR 2013-15-008 January 4, 2013 83. Interest rate hedging (locks and swaps)
Rev. Proc. 2012-28 July 2, 2012 72. Cancellation of debt income
PLR 2012-08-021 November 1, 2011 59. Interest rate hedging; forward swaps
PLR 2009-19-019 January 23, 2009 41. Interest rate hedging
PLR 2008-41-017 June 16, 2008 37. Interest rate hedging
PLR 2006-35-008 May 23, 2006 25. Interest rate hedging
PLR 2004-11-018 November 26, 2003 22. Interest income (loans to operating subsidiaries)
PLR 97-01-006 September 24, 1996 14. Interest income (loan originations by non-financial business)
PLR 96-19-011 January 30, 1996 12. Derivative transactions, financing and inventory arrangements, separate services and end-user sales
IRS Guidance Date Activity
PLR 2011-13-018 December 8, 2010 51. Subpart F income (marketing subsidiary)
PLR 2007-28-025 March 23, 2007 31. Subpart F income (CDO)
PLR 2007-22-007 February 26, 2007 29. Subpart F income (CDO)
IRS Guidance Date Activity
PLR 2017-41-001 June 29, 2017 147. Production, storage, transportation, and marketing of a nitrogen-based fertilizer; rental income arising under a ground lease, including percentage rents
PLR 2016-19-002 May 6, 2016 136. Fertilizer production, storage, transportation and marketing
PLR 2013-31-002 April 16, 2013 89. Sale of liquid urea for non-agricultural use (DEF production)
PLR 2013-08-004 November 5, 2012 77. Sales of fertilizer products and byproducts for non-agricultural use
PLR 2012-16-022 December 2, 2011 60. Hydrogen byproduct sales
PLR 93-39-014 June 28, 1993 5. Sale of nitric acid, carbon dioxide and gas futures (as part of a fertilizer business)
IRS Guidance Date Activity
PLR 2017-22-023 February 28, 2017 142. Processing, transportation, storage, and marketing of wood pellets and wood chips
PLR 99-32-024 May 13, 1999 20. Glued wood products
PLR 98-22-035 February 26, 1998 18. Sales of wood products
PLR 98-22-034 February 26, 1998 17. Production and sale of engineered wood products
PLR 94-50-029 September 19, 1994 9. Plywood and sawmill operations
PLR 93-38-028 June 25, 1993 4 . Plywood and fiberboard operations
PLR 91-05-015 November 1, 1990 3. Sawmill operation
PLR 90-08-035 November 24, 1989 1. Pulp mill operation
IRS Guidance Date Activity
PLR 2018-19-001 January 30, 2018 150. Inadvertent termination relief due to section 965 subpart F inclusion
PLR 2018-18-001 February 1, 2018 149. Inadvertent termination relief due to section 965 subpart F inclusion